{"operation":"document","citation":"CPF 12022073NOA","title":"WILD GOOSE STORAGE LLC — Notice of Amendment","source_type":"enforcement","agency":"Pipeline and Hazardous Materials Safety Administration","status":"historical","official":true,"published_on":"2022-10-06","effective_on":null,"summary":"CLOSED notice of amendment citing 192.12(c).","machine_formats":{"json":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022073noa.json","markdown":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022073noa.md"},"app_url":"https://regulus.evalyn.ai/document/phmsa-enforcement-12022073noa","source_url":"https://primis.phmsa.dot.gov/enforcement-data/case/12022073NOA","body":"Notice of Amendment involving WILD GOOSE STORAGE LLC. PHMSA's enforcement data identifies the cited regulation as 192.12(c). The case was opened on 2022-10-06 and is reported as closed as of 2023-02-02. Open the official case record for notices, responses, orders, and the latest status.\n\nOfficial case documents:\n\n12022073NOA_Closure Letter_02022023_(21-207372).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022073NOA/12022073NOA_Closure%20Letter_02022023_(21-207372).pdf\n\n12022073NOA_Closure Letter_02022023_(21-207372)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022073NOA/12022073NOA_Closure%20Letter_02022023_(21-207372)_text.pdf\n\n12022073NOA_Notice of Amendment_10062022_(21-207372).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022073NOA/12022073NOA_Notice%20of%20Amendment_10062022_(21-207372).pdf\n\n12022073NOA_Notice of Amendment_10062022_(21-207372)_text.pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022073NOA/12022073NOA_Notice%20of%20Amendment_10062022_(21-207372)_text.pdf\n\n12022073NOA_Operator Response to Notice_11042022_(21-207372).pdf: https://primis.phmsa.dot.gov/enforcement-documents/12022073NOA/12022073NOA_Operator%20Response%20to%20Notice_11042022_(21-207372).pdf\n\n12022073NOA_Notice of Amendment_10062022_(21-207372)_text.pdf\n\nNOTICE OF AMENDMENT\nVIA ELECTRONIC MAIL TO: Toby.McKenna@rockpointgs.com\nOctober 6, 2022\nMr. Toby McKenna\nChief Executive Officer\nWild Goose Storage, LLC\n607-8th Ave. SW\nSuite 400\nCalgary, AB T2P 0A7\nCPF 1-2022-073-NOA\nDear Mr. McKenna:\nFrom April 19, 2021 through April 22, 2021, an inspector from the California Geologic Energy\nManagement Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA), pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Wild Goose Storage LLC’s (WGS) Wild Goose Storage Field in Gridley, California.\nOn the basis of the inspection, PHMSA has identified the apparent inadequacies found within\nWGS plans or procedures, as described below:\n1. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\n\n\n\nor beginning an activity not yet implemented.\nWGS’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,\nWGS’s Risk Management Plan (RMP) Section 4.6.1, Monitor for Presence of Gas in All Annuli\n(Section 4.6.1) did not include sufficient detail regarding how annular gas occurrences that are\ndeemed anomalous are defined and evaluated in accordance with API RP 1171, Section 9.3.2\n(Section 9.3.2).\nSection 9.3.2 states in part, “[t]he operator shall evaluate each annular gas occurrence that exceeds\noperator- or regulatory-defined threshold levels determined from well integrity evaluation and\nfrom risk assessment.” RMP Section 4.6.1 stated in part, “WGS measures and records all annular\nand tubing pressure each day. Annular gas occurrences that are deemed anomalous will be\nevaluated and reported to the Division.”\nDuring the inspection, CalGEM reviewed WGS’s RMP Section 4.6.1 and found that it did not\ninclude the process of how occurrences of annular gas that are deemed anomalous are determined\nand evaluated in its procedures.\nTherefore, WGS’s written procedures required by § 192.12(c) were inadequate. WGS must revise\nits written procedures to include how annular gas occurrences that are deemed anomalous are\ndefined and evaluated pursuant to Section 9.3.2.\n2. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nWGS’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,\nWGS’s Task Information and Practices System (TIPS) Work Task #7, Well Pad Gas Detection\n(Work Task 7) and Work Task #10, Wellhead Valve Function Test (Work Task 10) did not include\nsufficient detail to ensure consistent performance of the tasks, in accordance with API RP 1171,\nSection 9.3.2 (Section 9.3.2).\nSection 9.3.2 states in part, “[t]he operator shall visually inspect each wellhead assembly at least\nannually for leaks. The operator shall test the operation of the master valve and wellhead pipeline\n\n\n\nisolation valve at least annually for proper function and ability to isolate the well.”\nDuring the inspection, CalGEM reviewed WGS’s TIPS Work Task 7 and Work Task 10. Work\nTask 7 included seven steps to be followed to complete the task, while Work Task 10 included\neight steps to be followed to complete the task. CalGEM noted that Work Task 7 step 2 and Work\nTask 10 step 4 did not provide sufficient details about the gas detection equipment to be used and\nthe gas detection process. In addition, Work Task 7 step 5 did not provide sufficient detail about\nthe process of taking caisson readings below grating level. The lack of detail regarding these\nprocesses could possibly result in operator error.\nTherefore, WGS’s written procedures required by § 192.12(c) were inadequate. WGS must revise\nits written procedures to include sufficient detail to ensure consistent performance of Work Task\n7 and Work Task 10.\n3. § 192.12 Underground natural gas storage facilities.\n(a) …\n(c) Procedural manuals. Each operator of a UNGSF must prepare\nand follow for each facility one or more manuals of written procedures\nfor conducting operations, maintenance, and emergency preparedness\nand response activities under paragraphs (a) and (b) of this section.\nEach operator must keep records necessary to administer such\nprocedures and review and update these manuals at intervals not\nexceeding 15 months, but at least once each calendar year. Each\noperator must keep the appropriate parts of these manuals accessible\nat locations where UNGSF work is being performed. Each operator\nmust have written procedures in place before commencing operations\nor beginning an activity not yet implemented.\nWGS’s written procedures for conducting operations, maintenance, and emergency preparedness\nand response activities were inadequate to ensure safe operation of a pipeline facility. Specifically,\nWGS’s RMP did not include a process to use risk assessments as a basis for developing integrity\ndemonstration, verification, and monitoring tasks and evaluating their frequency requirements in\naccordance with API RP 1171, Section 9.2.2 (Section 9.2.2).\nSection 9.2.2 states, in part, that “[r]isk assessments shall be used as a basis for developing the\nintegrity demonstration, verification, and monitoring tasks and evaluating their frequency\nrequirements (see Section 8).”\nDuring the inspection, CalGEM reviewed WGS’s RMP, Section 5.1, Field-Wide Quantitative Risk\nAssessment (Section 5.1). WGS provided Section 5.1 as the process used to meet the requirement\nin Section 9.2.2. However, Section 5.1 did not include a description or process for how risk\nassessments were used as a basis for developing integrity demonstration, verification, and\nmonitoring tasks and evaluating their frequency requirements.\nTherefore, WGS’s written procedures required by § 192.12(c) were inadequate. WGS must revise\nits written procedures to include the use of risk assessments as a basis for developing integrity\n\n\n\ndemonstration, verification, and monitoring tasks and evaluating their frequency requirements.\nResponse to this Notice\nThis Notice is provided pursuant to 49 U.S.C. § 60108(a) and 49 C.F.R. § 190.206. Enclosed as\npart of this Notice is a document entitled Response Options for Pipeline Operators in Enforcement\nProceedings.\nPlease refer to this document and note the response options. Be advised that all material you\nsubmit in response to this enforcement action is subject to being made publicly available. If you\nbelieve that any portion of your responsive material qualifies for confidential treatment under 5\nU.S.C. 552(b), along with the complete original document you must provide a second copy of the\ndocument with the portions you believe qualify for confidential treatment redacted and an\nexplanation of why you believe the redacted information qualifies for confidential treatment under\n5 U.S.C. 552(b).\nFollowing the receipt of this Notice, you have 30 days to submit written comments, revised\nprocedures, or a request for a hearing under §190.211. If you do not respond within 30 days of\nreceipt of this Notice, this constitutes a waiver of your right to contest the allegations in this Notice\nand authorizes the Associate Administrator for Pipeline Safety to find facts as alleged in this Notice\nwithout further notice to you and to issue an Order Directing Amendment. If your plans or\nprocedures are found inadequate as alleged in this Notice, you may be ordered to amend your plans\nor procedures to correct the inadequacies (49 C.F.R. § 190.206). If you are not contesting this\nNotice, we propose that you submit your amended procedures to my office within 30 days of\nreceipt of this Notice. This period may be extended by written request for good cause. Once the\ninadequacies identified herein have been addressed in your amended procedures, this enforcement\naction will be closed.\nIt is requested (not mandated) that Wild Goose Storage, LLC maintain documentation of the safety\nimprovement costs associated with fulfilling this Notice of Amendment (preparation/revision of\nplans, procedures) and submit the total to Robert Burrough, Director, Eastern Region, Pipeline and\nHazardous Materials Safety Administration, 840 Bear Tavern Road, Suite 300, West Trenton, NJ\n08628. In correspondence concerning this matter, please refer to CPF 1-2022-073-NOA and, for\neach document you submit, please provide a copy in electronic format whenever possible. Smaller\nfiles may be emailed to robert.burrough@dot.gov. Larger files should be sent on USB flash drive\naccompanied by the original paper copy to the Eastern Region Office.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration\nEnclosure: Response Options for Pipeline Operators in Enforcement Proceedings\n\n12022073NOA_Closure Letter_02022023_(21-207372)_text.pdf\n\nVIA ELECTRONIC MAIL TO: Toby.McKenna@rockpointgs.com\nFebruary 2, 2023\nMr. Toby McKenna\nChief Executive Officer\nWild Goose Storage, LLC\n607 -8th Ave. SW\nSuite 400\nCalgary, AB T2P 0A7\nCPF 1-2022-073-NOA\nDear Mr. McKenna:\nFrom April 19, 2021, through April 22, 2021, an inspector from California Geologic Energy\nManagement Division (CalGEM), acting as an agent for the Pipeline and Hazardous Materials\nSafety Administration (PHMSA) pursuant to Chapter 601 of 49 United States Code (U.S.C.)\ninspected Wild Goose Storage LLC’s procedures for Wild Goose Storage field in Gridley,\nCalifornia. As a result of the inspection, Wild Goose Storage LLC was issued a Notice of\nAmendment on October 6, 2022, with a request for further amendment on December 22, 2022,\nwhich proposed amendment of your procedures.\nWild Goose Storage LLC submitted its amended procedures on November 4, 2022, for the Notice\nof Amendment dated October 6, 2022, and responded to the Request for Further Amendment on\nJanuary 20, 2023, in response to the Request for Further Amendment dated December 22, 2022.\nMy staff reviewed the amended procedures, and it appears that the inadequacies outlined in this\nNotice of Amendment have been corrected.\nThis letter is to inform you no further action is necessary and this case is now closed. Thank you\nfor your cooperation.\nSincerely,\nRobert Burrough\nDirector, Eastern Region\nPipeline and Hazardous Materials Safety Administration","truncated":false,"body_characters":12944}